Currently, the Turkish authorities are only accepting pre-registrations of all chemical substances which are manufactured/imported into Turkey in 1 ton/year or greater. The pre-registration deadline for chemical substances according to KKIDK (Turkey REACH) is approaching soon and is currently set at Dec. 31st 2020. In order to benefit from the grace period for registration until Dec. 31st 2023, pre-registration must be completed before the deadline.
The KKDIK regulation was published on Jun. 23rd 2017 and implemented officially on Dec. 23rd 2017. The competent authority in Turkey is the Ministry of Environment and Urbanization of the Turkish Republic (MoEU). KKDIK is an acronym for the Turkish translation of Registration, Evaluation, Authorisation and Restriction of chemical substances. The regulation is modelled on the EU REACH regulation and shares many similarities in its structure and data requirements.
The scope of registration is the same as with EU REACH. The obligation applies to
1. All chemical substances manufactured/imported into Turkey in 1 ton/year or greater regardless of tonnage, substance type etc.;
2. Substances in mixtures which are present in 1 ton/year or greater;
3. Substances in articles which are intended to be released under normal or foreseeable conditions of use and where the total is 1 ton/year or greater;
4. Monomeric unit(s) or other reactive units of a polymer where:
(a) The polymer consists of 2% (w/w) or greater of the monomeric substance(s) or substances(s) in the form of monomeric units and chemically bound substances(s)
(b) The total quantity of monomer substance(s) or other substances(s) totals 1 ton/year or greater.
Registration must be completed by a Turkish manufacturer/importer. However, foreign enterprises may appoint an only representative based in Turkey which fulfils the obligations of an importer. OR appointment is the same process as with EU REACH.
Enterprises which receive their pre-registration number before the deadline can avail of the registration grace period until Dec. 31st 2023. This means they can manufacture/import their chemical substances into Turkey during this period. However, enterprises must ensure they have completed registration before Jan. 1st 2024 or they will no longer be entitled to manufacture/import into Turkey.
The mandatory information for pre-registration includes substance name, CAS number, EC number, substance structure etc.
C&L Notification
C&L notification applies to the classification and labelling of hazardous chemicals in Turkey. If the chemical substance meets hazardous criteria, C&L notification must be done within 1 month of manufacture/import. The SEA Regulation (28848) in Turkey aligns itself with CLP in the EU. C&L notifications can be submitted via the KKS tool of Environmental Information System (EIS) and an ESBS account needs to be established. However, only a Turkish manufacturer/importer may submit a C&L notification. The pre-registration obligation is fulfilled under C&L notification.
Julie Harrington, Regulatory Affairs Consultant
CIRS, Europe Email:julie@cirs-reach.com Web: www.cirs-reach.com
